Many others are taking on the burden themselves and utilizing their inhouse team of Regulatory, Finance, and IT staff.

For you, KHC can help in the following areas:

• Answering questions regarding the rules and their specific application.
• Performing a review of your results – as a quality check.
• Help you handle certain portions of the updates needed – you define and you control.
• Training staff on ways to facilitate the data burdens and the Hospital Price Transparency rules.

If these or other areas of assistance are needed, please contact Sara Rivenburgh (srivenburgh@kohlerhc.com) or Linker Mills (lmills@kohlerhc.com).

Physicians are becoming employees of the Hospital or hospital enterprise. The level of reimbursement challenges and Practice hassles have combined to change the concerns of purchasers from “how much should we pay for the Practice” to “how can we be sure that we are paying appropriately and billing compliantly.” Increased Practices are being purchased, but the private practice approach by the physician may be hard to meld easily with the Hospital environment.

Their concerns are not always the same as the Hospital, yet there needs to be an understanding and agreement of how specific issues should be handled—such as staffing, patient care coverage, documentation, coding and billing.

Specific Issues Being Faced:

• Fair Market Value of Amount
  • How to base compensation initially and fairly set rates for the future. Understanding and implementing features to measure individual productivity (including bundling of services) and use of non-physician providers in RVU methodologies.
• Medicaid Requirements Different than Medicare
  • In some states, Medicaid will not pay for a professional fee and the facility fee billed on separate claims—UB and Form 1500. Determine if the billing is provider-based, and what methodology is compliant for each payer.
• Documentation of Services Provided
  • Moving the physician to needed standards is challenging dependent upon the way the physician has been documenting in private practice.
• Selection of Codes/Services to Be Billed
  • This is always a key component of any physician compliance plan. We provide an unique approach creating understanding and improvement to address ongoing income considerations of pricing and contract needs to be evaluated.

Approach to Improvements

The philosophical approach to compliance and operations is to evaluate the details while understanding the global problems, and implement understandable guidance and specific tools to allow our providers to succeed.

We have assisted a variety of health care organizations for over 15 years on a diverse number of projects including medical staff development plans, new program evaluation and implementation, feasibility studies regarding health system business opportunities, and grant writing.

Examples of Our Depth of Expertise

• Grant and Proposal Development and Writing: Successfully wrote 6 grants and proposals to local, state, and Federal agencies on behalf of FQHCs and hospitals in 2009 and 2010; Represent acute care hospitals and large physician group practices on health plan contract analysis, reimbursement strategy and negotiations.
• Performed Medical Staff Development Plans (MSDP) for 15 hospitals since 2000 that identified opportunities to fortify the medical staff, existing service lines, and establish new programs for the market place. These MSDPs also focused on physician demand/need, recruitment/retention, and leadership issues.
• Since 2000, have assisted over 12 hospitals and four large (25+ physicians) medical groups on market assessments and development of long range and shorter term business plans focused on service line enhancement and capital allocation. Worked closely with planning task forces comprising executive team members, physician leadership and Board of Trustees.
• Prepared annual “Community Benefit Program” submissions on behalf of acute care hospitals that are required by the IRS on the 1099 form.
• Facilitated executive and medical staff leadership planning retreats for several hospitals and large physician groups focused on establishing a meaningful dialogue that further advances the relationship between the Hospital and the medical staff.
• Since 1999 assisted many hospitals in the development and review of physician compensation plans to align goals and results.

Health systems rely on KHC as the first step in acquiring a physician practice to clearly understand the financial, regulatory, reimbursement, compliance, and operational aspects of the targeted practice. Our physician practice acquisition due diligence process encompasses the following elements:

• Identifying key characteristics of desired acquisitions
• Historical financial performance assessments
• Physician compensation, productivity and RVU calculation/benchmarking
• Operational expenses benchmarking
• Professional fee revenue cycle operations assessment and improvement strategies
• Coding and medical record documentation issues
• Compliance and regulatory matters
• Managed care contracting assessments
• Pro forma financial planning
• Integration planning, including:
  • Governance
  • Management structure and human resources integration, analysis and planning
  • Physician compensation plan design
  • Office location
  • Ancillary services impact analysis
  • Communications planning

Community benefits are programs or activities that promote health and healing in response to identified community needs and meet at least one of these community benefit objectives:

• Improve access to health care services
• Enhance the health of the community
• Advance medical or health care knowledge
• Relieve or reduce the burden of government or other community efforts

In order to comply with Federal tax-exemption requirements in the Affordable Care Act, a tax-exempt hospital facility must:

• Conduct a Community Health Needs Assessment (CHNA) every three years. The assessment must take into account input from persons who represent the broad interests of the community served by the hospital facility, including those with special knowledge of or expertise in public health.
• Adopt an implementation strategy to meet the community health needs identified through the assessment.
• Report how it is addressing the needs identified in the community health needs assessment and a description of unmet needs with the reasons why such needs are not being addressed. Key components of the CHNA should include the following:
  • Plan and Prepare for the Assessment
  • Determine the Purpose and Scope of the Community Health Needs Assessment
  • Identify Data that Describes the Health Needs of the Community
  • Understand and Interpret the Data
  • Define and Validate Priorities
  • Document and Communicate Results

Kohler HealthCare Consulting has experienced talent available and able to fill the following positions:

• Chief Financial Officer (CFO)
• Chief Nursing Officer (CNO)
• Chief Compliance Officer (CCO)
• Central Office Billing Director
• Clinical Documentation Improvement (CDI) – Manager to Director
• Health Information Manager (HIM) – Director
• Skilled Nursing Facility Director
• Professional Practice Manager

For Short Term, Intermediate or For A Special Project In Support of Your Needed Directors and Managers

Kohler HealthCare Consulting has project managers who understand how to deliver a variety of projects including:

• Complex, multi-organization projects
• Compliance plan analytics, development or issue resolution
• Projects involving employed and non-employed physicians and non-physician practitioners/providers
• Projects that require engaging Unions
• Gap analysis to verify service or department improvements towards best practices
• Data analytics to discover the opportunities

KHC is experienced in working in hospitals and health systems, pre- and post-acute levels of care (SNF and Home Care), medical practices, CBOs, as well as understanding the special needs and environments of Federally Qualified Health Centers (FQHCs), Community Centers, and Critical Access Hospitals (CAHs).

Other projects include the implementation of ICD-10 and implementation of EPIC (and other comprehensive system) resolutions. We can help you move forward.

Our services are flexible and can be provided remotely, as a combination of remote and onsite or full-time onsite as needed.

Care Management is practiced by hospitals to coordinate care for patients to ensure health needs are met, proper usage of available resources and to promote high quality and cost effective outcomes. It is also the necessary front end of the Revenue Cycle that assures the financial health of the hospital, as well as the proper care plan for the patient.

Kohler HealthCare Consulting understands both the difficulties faced by Care Managers, as well as the financial impact—improvements needed throughout the entire process to ensure this dual success. Care Managers are instrumental in the coordination of care and resources, and are crucial in identifying areas of concern and thus precipitate change from the determination of care needed to the final disposition of the patient’s care. Success in these tasks requires a functional and focused approached with the right people and the right support.

We evaluate and implement—then monitor to assure lasting results.

Our Approach to Improvements

KHC is here to support the goals of Care Management, and the financial performance of the hospital, by facilitating the delivery of quality and appropriate care in a cost-effective manner while seeking to promote positive heath care outcomes. KHC will help you support these overall goals by:

• Reviewing and evaluating your current Care Management model, its effects on the organization, or the effects on patient outcomes, and compare the model to best practices.
• Assessing current practices, actual documentation, and decision making in the use of Observation status and identify steps for improvement.
• Evaluating methodology used in determining Observation hours to be billed.
• Reviewing patient flow and UM criteria/decision making and related documentation for all types of admissions.
• Evaluating data maintained and determine if data collection is sufficient to measure the effectiveness of the Care Management Program.
• Working with UM/CM staff and the physician advisor to evaluate issues faced and best practices to accomplish goals.
• Reviewing UM data that is collected by your facility – evaluate trends and recommend Care Management interventions to improve results.